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A company has requested a ruling on whether a two-step restructuring (contributions of shares followed by a subsequent exchange of securities) can qualify for the special regime under the Corporate Income Tax Act (LIS). The DGT indicates that for contributions, specific shareholding percentages must be met, and for the exchange, the majority of voting rights must be obtained, in addition to demonstrating valid economic reasons.
Question raised: Eligibility of the restructuring operation proposed in two steps for the special regime established in Chapter VII of Title VII of the LIS, and whether the economic motives proposed can be understood as valid for the purposes of applying said regime.
Para las aportaciones no dinerarias, los contribuyentes deben participar en los fondos propios de la entidad receptora en al menos un 5% y cumplir los requisitos de posesión ininterrumpida. En el canje de valores, la entidad debe adquirir una participación que le permita obtener la mayoría de los derechos de voto. Finalmente, el régimen no se aplicará si el objetivo principal es el fraude o la evasión fiscal, requiriéndose motivos económicos válidos como la racionalización de actividades, cuya validación dependerá de los hechos concretos.
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